Jul. 1, 2026
I am writing to provide comments on the SEC's proposed amendments to Exchange Act Rule 15c2-11. While I appreciate the Commission's efforts to clarify the scope of Rule 15c2-11, I encourage the SEC to also consider broader reforms affecting over-the-counter (OTC) equity securities, particularly those placed in the Expert Market. The current framework can unfairly disadvantage investors in companies that remain legally active at the state level but no longer have publicly available quotations through retail broker-dealers. Many companies continue to exist as valid legal entities under state corporate law, continue to file required state filings, or are actively pursuing restructuring, custodianship, or revival. Despite this, ordinary shareholders are effectively prevented from buying or selling their securities because quotations are unavailable and most brokers do not permit trading. I support the SEC's objective of protecting retail investors by requiring transparency and current information. However, preventing trading altogether for existing shareholders is an unnecessarily restrictive outcome that significantly reduces liquidity and limits shareholder rights. I encourage the Commission to consider reforms that would preserve investor protections while restoring the ability to trade these securities. Potential approaches include: Allowing broker-dealers to display quotations for Expert Market securities with clear and prominent risk disclosures. Permitting retail investors to buy and sell Expert Market securities after acknowledging the associated risks through their brokerage platform. Establishing a regulated framework that allows trading in these securities while maintaining appropriate disclosure requirements. Creating additional pathways for companies that remain active under state law, or are undergoing lawful revival or custodianship proceedings, to regain public quotations without disproportionate regulatory burdens. Investors should have the freedom to make informed decisions about whether to trade these securities. Restricting access to quotations and effectively eliminating trading can leave shareholders with investments they cannot readily sell, even when there are willing buyers and sellers. A balanced regulatory framework can protect investors while preserving market liquidity and respecting shareholder rights. Thank you for considering these comments and for evaluating ways to improve the fairness and efficiency of the OTC market.